Saturday, December 12, 2015

U.S. Department of Transportation 

Docket Management System 

1200 New Jersey Ave., SE 

Washington, D.C. 20590 

 RE: Petition of Charles L. Ferrell for Exemption from Certain Federal Aviation 

 Regulations to Operate Unmanned Aircraft Systems Pursuant to section 333 

 of the FAA Modernization and Reform Act 

Dear Sir or Madam: 

This petition is being submitted on my behalf without legal counsel or consulting services. 

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (the Reform Act), 

and 14 C.F.R. Part 11, Charles Ferrell, a freelance multimedia producer, hereby applies for an 

exemption from the Federal Aviation Regulations (FARs) listed below to allow operation of 

Small Unmanned Aircraft System (sUAS) commercially in airspace regulated by the Federal 

Aviation Administration (FAA) so long as such operations are conducted with and under the 

conditions outlined herein or as may be established by the FAA as required by Section 333. 

Charles L. Ferrell seeks to use to (sUAS) to conduct aerial data collection that will serve a 

variety of functions including newsgathering, search and rescue, commercial production, real 

estate, marketing, and special events. 

Grant of this petition will enable Charles L. Ferrell to assist public safety and local authorities 

that might not have immediate access to the same type of imagery (much in the same way that 

manned aircraft assist public safety and local authorities today). Authorization to operate UAS 

will enable Charles L. Ferrell to provide information and imagery to the public that is otherwise 

unavailable given existing barriers, such as those created by environmental hazards. 

Charles L. Ferrell complies with local ordinances and laws regarding the operation of sUAS, and 

adheres to all weather and environmental restrictions or limitations in reference to the operations 

of sUAS. 

All flights will occur in ordinance with any state or local laws regarding privacy.

I, Charles L. Ferrell, am seeking the exemption because I am committed to complying with all of 

the rules, guidelines, limitations, and future legislation set forth by the FAA. I agree to operate 

the sUAS in the manner that I have described, and for the purposes that I have described. 
Without the exemption request granted, I would be unable to safely and effectively run my 

business, and it is my intention to comply with the FAA and obtain an exemption of 

the following regulations. 

The following contains my list of regulations from which I am seeking exemption, and a 

complete list of responsibilities I assume as operator; it also contains information regarding the 

aircraft, public benefit and safety features, and similar petitions requests granted. 

Regulations from which exemption is requested: 

14 C.F.R. Part 21 

14 C.F.R. 45.23(b) 

14 C.F.R. 91.7(a) 

14 C.F.R. 91.9(b) (2) 

14 C.F.R. 91.109 

14 C.F.R. 91.119 

14 C.F.R. 91.121 

14 C.F.R. 91.151(a) 

14 C.F.R. 91.203(a) & (b) 

14 C.F.R. 91.205(b) 

14 C.F.R. 91.215 

14 C.F.R. 91.401 -91.417

I. OPERATING PARAMETERS 

1. Operations authorized by this grant of exemption are the DJI Phantom, DJI Phantom 2, DJI 

Phantom 3, and the DJI Inspire 1, all of which are well below 55 pounds including payload. 

2. Operations for the purpose of closed-set motion picture and television filming are not 

permitted. 

3. The UA may not be operated at a speed exceeding 87 knots (100 miles per hour). The 

exemption holder may use either groundspeed or calibrated airspeed to determine compliance 

with the 87 knot speed restriction. In no case will the UA be operated at airspeeds greater than 

the maximum UA operating airspeed recommended by the aircraft manufacturer. 

4. The UA must be operated at an altitude of no more than 400 feet above ground level (AGL). 

Altitude must be reported in feet AGL. 

5. The UA must be operated within visual line of sight (VLOS) of the PIC at all times. This 

requires the PIC to be able to use human vision unaided by any device other than corrective 

lenses, as specified on a U.S. driver’s license. 9. The operator is responsible for maintaining and 

inspecting the UAS to ensure that it is in a condition for safe operation. 

6. Prior to each flight, the PIC must conduct a pre-flight inspection and determine the UAS is in 

a condition for safe flight. The pre-flight inspection must account for all potential discrepancies, 

e.g., inoperable components, items, or equipment. If the inspection reveals a condition that 
affects the safe operation of the UAS, the aircraft is prohibited from operating until the necessary 

maintenance has been performed and the UAS is found to be in a condition for safe flight. 

7. The operator must follow the UAS manufacturer’s maintenance, overhaul, replacement, 

inspection, and life limit requirements for the aircraft and aircraft components. 

8. Each UAS operated under this exemption must comply with all manufacturer safety bulletins. 

9. The UA may not operate within 5 nautical miles of an airport reference point (ARP) as 

denoted in the current FAA Airport/Facility Directory (AFD) or for airports not denoted with an 

ARP, the center of the airport symbol as denoted on the current FAA-published aeronautical 

chart. 

10. If the UAS loses communications or loses its GPS signal, the UA must return to a predetermined location. 

11. The PIC must abort the flight in the event of unpredicted obstacles or emergencies. 

12. The PIC is prohibited from beginning a flight unless (considering wind and forecast weather 

conditions) there is enough available power for the UA to conduct the intended operation and to 

operate after that for at least five minutes or with the reserve power recommended by the 

manufacturer if greater. 

13. All aircraft operated in accordance with this exemption must be identified by serial number, 

registered in accordance with 14 CFR part 47, and have identification.

14. The UA must remain clear and give way to all manned aviation operations and activities at 

all times. 

15. The UAS may not be operated by the PIC from any moving device or vehicle. 

16. All Flight operations must be conducted at least 500 feet from all nonparticipating persons, 

vessels, vehicles, and structures unless: a. Barriers or structures are present that sufficiently 

protect nonparticipating persons from the UA and/or debris in the event of an accident. The 

operator must ensure that nonparticipating persons remain under such protection. If a situation 

arises where nonparticipating persons leave such protection and are within 500 feet of the UA, 

flight operations must cease immediately in a manner ensuring the safety of nonparticipating 

persons; and b. The owner/controller of any vessels, vehicles or structures has granted 

permission for operating closer to those objects and the PIC has made a safety assessment of the 

risk of operating closer to those objects and determined that it does not present an undue hazard. 

17. All operations shall be conducted over private or controlled-access property with permission 

from the property owner/controller or authorized representative. Permission from property 

owner/controller or authorized representative will be obtained for each flight to be conducted. 

18. Any incident, accident, or flight operation that transgresses the lateral or vertical boundaries 

of the operational area must be reported to the FAA's UAS Integration Office (AFS−80) within 

24 hours. Accidents must be reported to the National Transportation Safety Board (NTSB) per 

instructions contained on the NTSB Web site: www.ntsb.gov. 

II. SIMILAR EXEMPTIONS

They are similar in all/or many material respects to relief previously requested in Grant of 

Exemption Nos. 11062, 11109, 11112, and 11213 
III. PUBLIC BENEFIT AND SAFETY 

Unmanned Aircraft System sUAVs are often seen as superior to helicopters as an aerial video 

gathering platform due to the smaller devices cheaper equipment and personnel cost, reduced 

noise and as such, a much smaller environmental impact which promotes public safety. 

Charles L. Ferrell is petitioning for an exemption to operate the DJI Phantom, DJI Phantom 2, 

DJI Phantom 3, and the DJI Inspire 1 with a built-in stabilized HD camera and GPS safety 

features which limit its ability to limit the height it flies above ground level (AGL), to limit the 

radius of the distance it flies from the operator and to exclude it from operations within 

designated Class B, C and D airspace including a no-fly zone feature. 

The DJI Phantom, DJI Phantom 2, DJI Phantom 3, and the DJI Inspire 1 also have a failsafe 

function that is triggered in the event communication is lost between the sUAS and the main 

controller transmitter. At that time, the sUAS will return to its point of takeoff and land safety. If 

the connection is restored, the PIC can regain control of flight and land manually. 

IV. APPLICANT INFORMATION 

 The name and contact information of the applicant is: 

 Charles L. Ferrell 

 197 Fox Chase Drive 

 Duncansville, PA 16635